Privacy

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Privacy Notice

Cerris Homes is a trading name owned by ASPIRE HOUSING LIMITED. This privacy notice explains how ASPIRE HOUSING LIMITED will use any personal data you provide to us. Please read this notice carefully and make sure that you understand your rights and responsibilities.

From time to time, as our organisation evolves and develops we may update and make changes to this privacy notice.

1. Key Definitions

Automated individual decision-making is making a decision solely by automated means without any human involvement.

Data controller means a company or person who determines the purposes for which, and the manner in which personal data is processed. In this context this relates to Aspire Housing as an organisation.

Data subject means an individual who is the subject of personal data.

Data processor, in relation to personal data, means any person (other than an employee of the data controller) who processes the data on behalf of the data controller.

Data Protection Officer is the person responsible for overseeing Data Protection within the organisation.

Information Commissioners Office (ICO), The Information Commissioner's Office in the United Kingdom, is a non-departmental public body which reports directly to Parliament. They are responsible for implementing data protection law and carrying out enforcement actions.

Personal data means any information relating to an identified or identifiable natural person ("data subject"); an identifiable person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that person.

Processing means obtaining, recording or holding information or data or carrying out any operation or set of operations on that data.

Profiling is automated processing of personal data to evaluate certain things about an individual.

Regulator of Social Housing (RSH) regulates private registered providers of social housing. Aspire Housing is subject to their regulation.

2. Who we are

The data controller is ASPIRE HOUSING LIMITED.

ASPIRE HOUSING LIMITED is a leading housing provider, place shaper and property developer. We are a financially strong business. Profits are reinvested in new homes, in revitalising communities and in a comprehensive range of innovative support services, designed to transform lives.

ASPIRE HOUSING LIMITED is the parent company of PROJECT MANAGEMENT (STAFFORDSHIRE) LIMITED, and REALISE FOUNDATION [trading as Realise charity]. Each of these organisations have their own individual privacy notices that can be found on their web sites. ASPIRE HOUSING LIMITED also own the trading name Cerris Homes.

The Data Protection Officer (Tim Pratt) is the person responsible for overseeing Data Protection within the organisation and can be contacted at the above address.

3. Why we collect and use this information

How we collect personal information

We collect information in a variety of ways including, cookies using this website (see more information below); on various forms, tenancy agreements, and contracts; through our on- going contact with you; in some cases we collect CCTV images; and calls to and from our telephone lines and online chats are recorded.

When you apply to become an Aspire customer, we request and hold on file any references necessary to assess your application including as appropriate (but not limited to) references from other housing providers/private landlords, your mortgage lender (if you own/have owned your own home), the Police, the Probation Service, support workers, social workers, mental health workers and credit reference agencies.

If you provide us with personal information relating to members of your family or your associates we will assume that you do so with their knowledge.

It is important that you notify us of any changes to your personal information.

The information we collect

We collect personal information about:

Customers - This includes current, former and potential customers, who live in our properties or access our support and other services, and could also include their family and people associated with them (when you provide information about household members we assume that you do so with their full knowledge and consent).

Colleagues - This includes current, former and potential colleagues, as well as Board and Committee members, apprentices and volunteers.

Anyone who makes a complaint or enquiry and visitors to our website and offices

Whenever we collect personal information from you we will always issue you with a privacy notice at the point of collection explaining why we are collecting that personal data.

4. The purpose and lawful basis of using our records

We will collect, process, share and securely store personal information in order to operate as a registered provider of housing and deliver efficient and effective services.

All information will be retained in accordance with the requirements of our retention schedule.

Below we will describe the different lawful basis for processing personal (Section 4.1) and special categories of personal data (section 4.2). We will then describe the purposes and lawful basis under which Aspire Housing processes data (section 4.3).

4.1 Lawful basis for processing personal data

Under GDPR the lawful grounds for processing are set out in Article 6. At least one of these conditions must apply before Aspire Housing can process your personal data. The lawful conditions are as follows:

(a) Consent: Where the data subject has given clear consent for Aspire to process their personal data for a specific purpose. Where the processing is based on consent a data subject can withdraw that consent at any time.

(b) Contract: the processing is necessary for a contract Aspire has with a data subject, or because the data subject has asked Aspire to take specific steps before entering into a contract. You will note that we need to process personal data as part of the tenancy agreement between you and Aspire Housing.

(c) Legal obligation: the processing is necessary for us to comply with the law. Housing Associations are regulated by Homes England. We also have to comply with UK law.

(d) Vital interests: the processing is necessary to protect someone’s life.

(e) Public task: the processing is necessary for you to perform a task in the public interest or for your official functions, and the task or function has a clear basis in law.

(f) Legitimate interests: the processing is necessary for your legitimate interests or the legitimate interests of a third party unless there is a good reason to protect the individual’s personal data which overrides those legitimate interests.

We must still have a lawful condition for processing sensitive personal data, in exactly the same way as for any other personal data. The difference is that we will also need to satisfy a specific condition under Article 9. There are a number of conditions at article 9 but for Aspire Housing typically these are:

(a) Explicit Consent: the data subject has given explicit consent.

(b) Employment, social security and social protection law - Processing is necessary for the purposes of carrying out the obligations and exercising specific rights of the controller or of the data subject in the field of employment and social security and social protection law.

(c) Vital interests - Processing is necessary to protect the vital interests of the data subject or of another natural person where the data subject is physically or legally incapable of giving consent.

(h) Preventative or occupational medicine - processing is necessary for the purposes of preventive or occupational medicine, for the assessment of the working capacity of the employee, medical diagnosis, the provision of health or social care or treatment or the management of health or social care systems and services on the basis of Union or Member State law or pursuant to contract with a health professional and subject to the conditions and safeguards.

To find out more about the legal basis for processing personal data please visit the Information Commissioners Office (ICO) website: https://ico.org.uk/

The purpose and lawful basis under which Aspire Housing processes data

The purposes and legal basis for processing data under the GDPR are detailed in the tables below. This has been grouped into personal data about:

Customers

Colleagues

Other individuals who may make a complaint or enquiry

Customers

Purpose of collecting data

Lawful condition to process data

Contact our customers without delay

We have a legitimate interest to be able to contact our customers in order to maintain our housing stock. We hold telephone numbers and other contact details so that in an emergency (e.g. a gas leak) we can contact you without delay.

Make allocations of housing

As part of your tenancy agreement with Aspire we will ask you to provide us with information to prove your eligibility and suitability for the housing we provide. We collect that information as a legal obligation and also to perform your contract between you and Aspire Housing.

We will ask you to provide us with information about criminal convictions. The purpose of collecting this information is to identify any risks, and safeguard our other customers and staff. Where we ask for this information it will be in compliance with schedule 1 of the Data Protection Bill.

We will also ask you about your health in order to help with the allocation of a suitable property and services that Aspire Housing provide. Where we collect data concerning health (classed as special category data) we will only process that data based on your consent, and you have the right to remove that consent at any time.

We have a legitimate interest to contact third parties and check the validity of any information provided during the allocation process.

Manage tenancies

As part of your tenancy agreement with Aspire Housing we will ask you to continue to provide us with information and changes in your circumstances to assist us in managing your tenancy.

We also have a legitimate interest in holding information such as date of birth for the purpose of verifying we are speaking to the correct person in relation to a tenancy. If we did not take due diligence in verifying the identity of callers then we would not have appropriate measures to prevent unlawful access to personal data. (Please note we have a procedure for giving consent to allow a nominated representative to talk to us on your behalf).

We have a legitimate interest to keep information up to date in order to tailor our services to meet your individual needs and assist you in maintaining your tenancy. This may also include avoiding over occupying or under occupying of properties, to ensure our properties are utilised in the most effective way possible.

We also have a legitimate interest to ask if you would like to be referred to other organisations that may assist you in maintaining your tenancy. In this situation we will only pass on your personal information with your consent. You may remove your consent to this at any time.

Where we believe there to be concerns over safeguarding we have a legitimate interest to refer you on to the relevant services. It is also in the public interest to address concerns over safeguarding.

Receive rent and service charges

You are required to make service charge and rent payments as part of your tenancy agreement with Aspire Housing.

Ensure bills and benefits are accurate and paid accordingly

We have a legitimate interest to ensure that utility bills are passed to person who is responsible for the utility bill. If Aspire Housing is billed for the utilities of a tenant then we have a legitimate interest to pass the tenants details to the utility company.

We have a legitimate interest to ensure that tenants receive the benefits they are entitled to in order to have enough money to maintain their tenancies.

Provide a repairs and maintenance service

It is in Aspire’s legitimate interests to process data in order to repair and maintain our housing stock.

Aspire has a legal obligation to keep its housing stock in a good state of repair to satisfy section 11 of the Landlord and Tenant Act 1985.

We have a legal obligation to carry out gas safety checks.

In order to comply with the Health and Safety at Work Act 1974 we may need to carry out surveys on properties before commencing with repair work.

Failure to provide personal data

A failure to provide personal data that hinders our ability to carry out repairs and maintenance may result in legal proceedings or repairs not being carried out.

Offer help with debts and benefits

Aspire Housing has a legitimate interest in helping customers to be able to pay their bills and maintain their tenancies.

Provide Support services which help customers achieve their goals

Aspire Housing has a legitimate interest in helping customers achieve their goals and maintain their tenancies.

The Regulator of Social Housing (RSH) requires Housing Associations, such as Aspire Housing to work in partnership with local agencies to help promote social,

environmental and economic wellbeing. This is set out in the Neighbourhood and Community Standard.

Prevent & detect crime and resolve disputes

As part of your tenancy agreement you are required to engage with us to help resolve disputes with neighbours. We have a legitimate interest to prevent crime and resolve disputes in our neighbourhoods and communities. It is also in the public interest.

The RSH requires Housing Associations, such as Aspire Housing to work in partnership with local agencies to keep neighbourhoods safe and prevent anti-social behaviour. This is set out in the Neighbourhood and Community Standard.

We have a legitimate interest to promote safety and ensure our neighbourhoods and communities are enjoyable and safe places to live.

The RSH requires Housing Associations, such as Aspire Housing to work in partnership with local agencies to keep neighbourhoods safe, prevent anti-social behaviour, and to help promote social, environmental and economic wellbeing. This is set out in the Neighbourhood and Community Standard.

Engage with customers and make improvements to our products and services

The RSH requires Housing Associations, such as Aspire Housing to engage with customers over the delivery and performance of our service. This is set out in the Tenant Involvement and Empowerment Standard.

We have a legitimate interest to contact you and find out how we can improve our service through our market research surveys.

We also have a legitimate interest in making our products and services the best that they can be and promote the success of our organisation.

Membership of our customer forum is voluntary and processing of the data is by consent of the forum member. They can withdraw their membership at any time.

Marketing to encourage uptake of our services

We have a legitimate interest to send you information about services that may assist you in maintaining your tenancy.

You may ask us to remove you from our email alert lists at any time by unsubscribing within your customer account, or by clicking on any ‘unsubscribe’ link from one of our communications. You can also request to opt out by contacting our customer services team.

In the event of us using case studies or photographs of some of our success stories, we will always get the consent of the individuals featured in those photographs or case studies before sharing with other organisations or making public.

Keep records of Shared Ownership and Right to Buy

We have a legal obligation to collect information to prove eligibility for help to buy and prevent Fraud and Money Laundering. This will include affordability checks and identification checks.

Failure to provide personal data

A failure to provide personal data to prove eligibility may result in not being able to purchase a Shared Ownership or Right to Buy Property.

Provide employment and training advice and opportunities

Aspire Housing has a legitimate interest in helping customers find employment and maintain their tenancies.

The RSH requires Housing Associations, such as Aspire Housing to work in partnership with local agencies to help promote social,

environmental and economic wellbeing. This is set out in the Neighbourhood and Community Standard.

Record contact with customers

We have a legitimate interest to record telephone calls for training purposes.

We have a legitimate interest to record contact made through online contact forms, social media, email and other methods of contact. We may use this information to monitor the progress of enquiries and keep records of actions and decisions made throughout a tenancy.

Colleagues

Purpose of collecting data

Legal basis to process data

Keep and maintain up to date information about Directors to maintain statutory registers

We have a legal obligation to maintain statutory registers.

Maintain personnel files for all staff

We have a legal obligation to maintain certain records in relation to employees and a legitimate interest in keeping personnel files for all staff (namely as a record of the employment relationship).

This will include details of any training or other qualifications that may be required to be refreshed and updated after a certain amount of time.

For some job roles we may carry out regular Disclosure and Barring Service (DBS) checks where we have a legal obligation to safeguard our customers under the Safeguarding Vulnerable Groups Act 2006

as amended by the Protection of Freedoms Act 2012.

We have a legal obligation to ensure that all staff have the right to work in the UK under the Immigration, Asylum and Nationality Act 2006.

Giving or receiving of employee references

Where we receive employee references, it is because we have a legitimate interest in verifying your employment history and in order to assess your suitability for employment with us.

Process salary and expense payments

We have a legal obligation to keep records of expenses and salary payments. We need to process staff members bank details in order to pay salaries and expenses in accordance with the contract of employment.

Process pensions and other benefits

We have a legal obligation to keep records of pensions and any other benefits that a staff member may be receiving.

Maintain records of sickness and absence

We need to understand whether we should be paying sick pay. We have a legal obligation to pay statutory sick pay where an individual is entitled to, and it is necessary for the purposes of the contract of employment to assess entitlement to occupational sick pay.

We have a legitimate interest to keep levels of absence to a minimum.

Ensure staff are healthy and fit for work

Aspire Housing have a legal obligation to ensure that staff and apprentices are fit to work and/or remain in work. Typically this would involve a referral to an occupational health specialist to understand what support we can put in place, including a phased return to work and/or any reasonable adjustments and this report then being shared with Aspire Housing. Processing of this information is necessary for the purposes of assessing the working capacity of an employee and/or to obtain a medical diagnosis.

Ensure staff are compliant with relevant laws

Aspire Housing have a legal obligation to ensure that staff are operating within the law and any qualifications or licences required to carry out their roles are kept up to date (e.g. driving licence).

Maintain a register of accidents

Aspire Housing have a legal obligation to keep a record of accidents that occur within the organisation. This information may be used to understand patterns of behaviour and avoid future accidents. It may also be used to assist with the processing of future insurance claims.

Promote equal opportunities and fair treatment for all colleagues

We have a legal obligation to treat people fairly under the Equality Act 2010.

In order to do this Aspire Housing hold information on age, disability, gender, marriage and civil partnership, pregnancy and maternity, race, religion and belief and sexual orientation to ensure people are treated fairly and equally.

Manage employment and colleague development

Aspire Housing have a legitimate interest to use information to develop staff and apprentices to realise their potential and maximise their contributions to the organisation.

Staff and apprentices are encouraged to talk about their development needs in one-to-one meetings with their line managers.

Ensure compliance with policies and procedures and employee rules

We have a legitimate interest in ensuring that the policies and procedures which we implement for the benefit of the organisation are followed and that breach of them is addressed appropriately

Ensure effectiveness of systems and compliance with user policies

We have a legitimate interest to keep system logs of users to ensure compliance with the information Security and Systems usage policy.

We also have a legitimate interest to keep records of IT issues to help find resolutions to problems and maintain effective systems.

Record contact with Aspire Housing

We have a legitimate interest to record telephone calls for training purposes.

We have a legitimate interest to record contact made through online contact forms, social media, email and other methods of contact. We may use this information to monitor the progress of enquiries and keep records of actions and decisions made.

Other individuals who may make a complaint or enquiry

Purpose of collecting data

Legal basis to process data

Processing of job applications

Data received within job applications is processed on the basis of consent. An individual can withdraw that consent at any time.

For some job roles we may carry out regular Disclosure and Barring Service (DBS) checks where we have a legal obligation to safeguard our customers under the Safeguarding Vulnerable Groups Act 2006

as amended by the Protection of Freedoms Act 2012. It is also in our legitimate interests.

Where we receive employee references, it is because we have a legitimate interest in verifying your employment history and in order to assess your suitability for employment with us.

We have a legitimate interest to contact third parties and check the validity of any information provided during the recruitment process.

Failure to provide personal data

A failure to provide personal data may result in us being unable to assess the suitability of the candidate for the role.

Processing of complaints

The RSH requires Housing Associations, such as Aspire Housing must ensure that complaints are resolved promptly, politely and fairly. This is set out in the Tenant Involvement and Empowerment Standard.

It is our legitimate interest to process complaints data and understand how we can improve our services.

Keep staff and premises secure

Aspire Housing have a legitimate interest to keep premises and staff safe and secure with the use of CCTV.

Process enquiries about shared ownership sales

Individuals may contact Aspire Housing to find out about and receive marketing material on our shared ownership offering. This personal data is processed on the basis of consent and an individual can remove their consent to receive marketing material at any time.

Process Housing applications

We will ask you to provide us with information to prove your eligibility and suitability for the housing we provide. We collect that information as a legal obligation and also to perform your contract between you and Aspire Housing.

We will ask you to provide us with information with regard to criminal convictions. The purpose of collecting this information is to identify any risks, and safeguard our other customers and staff. Where we ask for this information it will be in compliance with schedule 1 of the Data Protection Bill. It is in our legitimate interests to safeguard out customers and staff. It is also in the public interest to address concerns over safeguarding.

We may also ask you about your health in order to help with the allocation of a suitable property and services that Aspire Housing provide. Aspire Housing has a legitimate interest in helping customers to be able to maintain their tenancies by making the most of the services we provide. Where we collect data concerning health (classed as special category data) we will only process that data based on your consent, and you have the right to remove that consent at any time.

We have a legitimate interest to contact third parties and check the validity of any information provided during the application process.

Contact suppliers, contractors, and maintain relationships with any other external organisations

It is our legitimate interest to hold contact details of individuals from the organisations we work in order for us to carry out our work as a housing association.

Record contact with enquirers

We have a legitimate interest to record telephone calls for training purposes.

We have a legitimate interest to record contact made through online contact forms, social media, email and other methods of contact. We may use this information to monitor the progress of enquiries and keep records of actions and decisions made off the back of an enquiry.

Profiling (automated processing of personal data to evaluate certain things about an individual). Profiling can be part of an automated decision-making process.

Aspire Housing analyse rent payment data to help understand which tenants are most likely to fall into arrears. This enables us to contact customers and help them manage their rent account and help them maintain their tenancy.

Aspire Housing may use automated decision making and profiling for recruitment and selection purposes.

5. Sharing your personal data

ASPIRE HOUSING LIMITED is committed to respecting and protecting your personal data. In certain circumstances we may need to share your personal data with other organisations. When we share personal data to complete a task we will only share the minimum personal data required to complete that task. We will never sell, rent or trade your personal data.

We will also pass your information on to third parties whom you may ask us to, for example if you ask us to put you in contact with professional advisors.

Who we share data with

We may share your data with the following organisations.

Auditors

Business associates and professional advisers

Charities and voluntary organisations

Courts and tribunals

Credit reference agencies

Current, past or prospective employers

Customers and clients

Debt collection and tracing agencies

Educators and examining bodies

Employees

Employment and recruitment agencies

Employee benefit providers

Enquirers and complainants

Fire service

Family, associates and representatives of the person whose personal data we are processing

Financial organisations

Health Authorities

Healthcare, social and welfare organisations

Landlords

Local and central government

Other companies in the same group as the data controller (PM Training, The Realise Foundation)

Other housing associations or trusts

Other voluntary and charitable organisations

Pension providers

Police forces

Property websites

Press and the media

Probation services

Professional advisers and consultants

Providers of goods and services

Repairs and maintenance contractors (It should be noted that within the terms and conditions of your tenancy agreement it states that you will allow contractors of Aspire access to your property to carry out repairs and maintenance).

Security organisations

Suppliers and service providers

Survey and research organisations

Homes England

Trade unions and associations

Trade, employer associations and professional bodies

6. Your Data Protection Rights

Under the GDPR you have the following main rights:

The right to be informed about how and why we gather your personal information, how we keep it and what we do with it.

The right to access the personal data we hold about you. This is known as a ‘subject access request (SAR). SARs need to be made in writing and we have one calendar month to provide you with the information you have asked for. The period of compliance may be extended to two months where requests are complex or numerous.

The right to have the information rectified if it is inaccurate or incomplete.

The right to have your information erased from our records. You can do this where:

the information is no longer necessary in relation to the purpose for which we originally collected/processed it

where you withdraw consent

where you object to the processing and there is no overriding legitimate interest for us continuing the processing

where we unlawfully processed the information

the personal information has to be erased in order to comply with a legal obligation

We can refuse to erase your personal information where the personal information is processed for the following reasons:

to exercise the right of freedom of expression and information;

to enable functions designed to protect the public to be achieved e.g. government or regulatory functions

to comply with a legal obligation or for the performance of a public interest task or exercise of official authority;

for public health purposes in the public interest;

archiving purposes in the public interest, scientific research historical research or statistical purposes;

the exercise or defense of legal claims; or

where we have an overriding legitimate interest for continuing with the processing

The right to object to processing where we say it is in our legitimate interests. We must stop using the information unless we can show there is a compelling legitimate reason for the processing, which override your interests and rights or the processing is necessary for us or someone else to bring or defend legal claims.

You have the right to require us to stop processing your personal information. When processing is restricted, we are allowed to store the information, but not do anything with it. You can do this where:

You challenge the accuracy of the information (we must restrict processing until we have verified its accuracy)

You challenge whether we have a legitimate interest in using the information

If the processing is a breach of the GDPR or otherwise unlawful

If we no longer need the personal data but you need the information to establish, exercise or defend a legal claim.

If we have disclosed your personal information to third parties, we must inform them about the restriction on processing, unless it is impossible or involves disproportionate effort to do so.

The right to request that your data be copied or transferred to another organisation in certain circumstances.

The right to complain to us and/or to the Information Commissioner’s Office if your information is being used unlawfully (contact details are below).

The right to challenge any automated decision making or profiling that may be carried out using your information.

If you would like to complain to the Information Commissioners Office the contact details are as follows: Information Commissioners Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF. https://ico.org.uk

7. Transfers to 3rd Countries

Where we transfer data outside of the EU we will only transfer data in compliance with the GDPR transfer rules. We have GDPR data processing agreements in place where data is hosted outside of the EU.

8. Website Cookies

Cookies are small text files placed on your computer by the websites you visit. They are used to help make websites work efficiently. You can control cookies through the settings of your web browser. To find out more, visit www.aboutcookies.org or www.allaboutcookies.org.

These are the cookies we use when you visit our website:

Google Analytics - to monitor website use and the type of browser that is accessing the website.

Google Translate - to remember a visitors language preferences.

Hotjar – to monitor website use and the type of browser that is accessing the website.

9. More information

You can find out more information on the GDPR on the Information Commissioners web site: https://ico.org.uk

You can also contact our data protection officer whose contact details are below: